No. 20-2-06439-0
SUMMONS
SUPERIOR COURT OF WASHINGTON IN AND FOR PIERCE COUNTY
RAINIER VIEW WATER COMPANY, INC.
Plaintiff,
v.
EUGENE L. IMUS AND PAULINE D. IMUS, HUSBAND AND WIFE, GREGORY H. O’BRIEN, A SINGLE MAN, RUTH E. GIESE, A SINGLE WOMAN, BERNICE F. OHMAN, A SINGLE WOMAN, GAYDON DEVELOPMENTS, INC., A DISSOLVED WASHINGTON CORPORATION, GAYLORD BUCK, A SINGLE MAN, AND JOHN AND JANE DOE 1-20
Defendants.
THE STATE OF WASHINGTON TO THE SAID DEFENDANTS EUGENE L. IMUS AND PAULINE D. IMUS, HUSBAND AND WIFE, GREGORY H. O’BRIEN, A SINGLE MAN, RUTH E. GIESE, A SINGLE WOMAN, BERNICE F. OHMAN, A SINGLE WOMAN, GAYDON DEVELOPMENTS, INC., A DISSOLVED WASHINGTON CORPORATION, GAYLORD BUCK, A SINGLE MAN, AND JOHN AND JANE DOE 1-20: You are hereby summoned to appear within sixty days after the date of the first publication of this summons, to wit, within sixty days after the 16th day of June, 2020, and defend the above entitled action in the above entitled court, and answer the complaint of the plaintiff Rainier View Water Company, Inc., and serve a copy of your answer upon the undersigned attorney for the plaintiff Rainier View Water Company, Inc., at his office below stated; and in case of your failure so to do, judgement will be rendered against you according to the demand of the complaint, which has been filed with the clerk of said court.
This is a quiet title action. The quiet title is to the parcels that are set out on Exhibit A, attached hereto. These parcels have been used since the 1970s for well sites and water distribution purposes. It appears that back at the time these well sites were conveyed to Neil and Paula Richardson or Richardson Water Companies, the deeds were incomplete. Since the time of conveyance, Neil and Paul Richardson (Richardson Water Companies) now Rainier View Water Company, Inc. have continuously operated those parcels as part of a water distribution system and have paid the taxes on them continuously. This action is to clear any question of title and be sure that the title is fully vested in Rainier View Water Company, Inc. or its successors in interest.
DATED this 15th day of June, 2020.
Richard A. Finnigan, WSBA #6443
Attorney for Plaintiff
2112 Black Lake Blvd. SW
Olympia, WA 98512
EXHIBIT A Parcel 0122132116
All that portion of the following described Parcel A lying Westerly of the West right of way line of SR-16, Narrows Bridge to Olympic Drive and Easterly and Northerly of the following described line: Beginning at a point on the South line of Lot 14, Block 2 of said Parcel A and 15 feet distant Southwesterly at right angles from the West right of way line of said SR-16; Thence Northwesterly parallel with said Westerly right of way to a point 60 feet Northerly of the North line of said Lot 14; Thence Westerly parallel with the North line of said Lot 14 to the West line of said Parcel A and the end of this line description.
Parcel A:
Lot 14, Block 2, Purdy Acres, according to the plat thereof recorded in Volume 31 of Plats at Pages 48 and 49, records of the Pierce County Auditor; Also, commencing at the Southwest corner of the Northeast quarter of the Northwest quarter of Section 13, Township 22 North, Range 1 East of the Willamette Meridian; Thence along the West line of said Subdivision North 415 feet to the Point of Beginning; Thence continuing along said West line North 246 feet; Thence parallel with the South line of said Subdivision East 1259.03 feet to the East line of said Subdivision; Thence along said East line South 246 feet to a line parallel with and 415 feet North of the South line of said Subdivision;
Thence along said parallel line West 1262.31 feet to the Point of Beginning; Except the West 50 feet thereof for State Highway; Also except that portion thereof conveyed to the State of Washington for Primary State Highway No. 14 by Deed recorded December 2, 1954 under recording number 1702032; Also except the East 530 feet; Situate in the County of Pierce, State of Washington.
Parcel 0221192036
Commencing at the Northwest corner of Section 19, Township 21 North, Range 2 East of the Willamette Meridian; Thence South along the West line of said Section 01°45’39” East 1403.85 feet; Thence North 85°54’30” East 160.35 feet to the Easterly line of Wollochet Bay Road; Thence along said Easterly line South 11°55’ East 120.50 feet; Thence South 89°15’10” East 448.83 feet to the Point of Beginning;
Thence South 28°49’ East 146.59 feet; Thence South 88°06’03” East to the Westerly right of way line of Wollochet Bay-Relocation Road; Thence Northwesterly along the Westerly right of way line of said road to a point South 89°15’10” East of the Point of Beginning; Thence North 89°15’10” West to the Point of Beginning; Situate in the County of Pierce, State of Washington.
IDX-901043
June 16, 23, 30, July 7, 14, 21, 2020
